Technical Assistance for Primary Response Contractors

On December 14, 2013 Washington
State adopted updates to the Oil Spill Contingency Plan Rule, Chapter 173-182
WAC. While most of the changes apply to facility and vessel contingency plan
holders there were some updates to the requirements for Primary Response
Contractors.

Primary Response Contractor Requirements fall under
the following rule sections:

Answer: The rule was adopted December 14th, 2012 and became effective
January 14th, 2013.

Question: What updated PRC requirements are in effect NOW?

Answer: All elements of 173-182-820 Significant Change Notification became
effective on the rule effective date.

Question: Where can I find information about the rule phase-in dates?

Answer: The rule phase-in dates are detailed in WAC 173-182-130. The next
phase in date affecting PRCs is the 18 month phase-in. For PRCs to be
incompliance with the 18 month phase-in all updates to the PRC application must
be submitted by July 14th, 2014.

Question: What does the 18 month phase-in require?

Answer: By July 14th, 2014 all primary response contractors must update their
applications to comply with WAC 173-182-810 Primary response contractor
application content, submittal and review. In order to address this requirement you may resubmit your entire PRC
application using the
updated PRC Application or submit updates to the
following sections of your approved PRC application:

Update the signature block in section B-SIGNATURE of the new application.
In the updated application we aligned the language in the signature block with
the old regulation and added two new commitment statements:

o Identifying and training staff and supervisors expected to be
deployed on oil spill response tactics or used to meet the plan holder planning
standards. WAC 173-182-800
o Maintaining a list of PRC response equipment on the Western
Response Resource List or provide an equivalent electronic equipment list and
confirm the accuracy of the list on a quarterly basis. WAC 173-182-810

Update training as described in section E-TRAINING INFORMATION
of the new PRC application.

The quarterly requirement to certify the accuracy of the equipment listed on
the WRRL phases in on July 14th, 2014. Please ensure your WRRL listing is
up to date when you submit your PRC application. Moving forward we will
send you an email reminder of the required WRRL accuracy update on or around the
following dates.
o October 1st
o January 1st
o April 1st
o July 1st

If your PRC application includes information for your customers (plan
holders) to reference in support of their compliance, you may also need to
update the following sections of your application:

Vessels of Opportunity Region - WAC 173-182-317 Update information in your
application describing how you meet the VOO requirements for the Straits
Region-1. The categories of information to include in your application are
detailed in the new PRC application section F3.

Aerial Surveillance Helicopter/Fixed Wing WAC 173-182-321 update your PRC
application to include the information described in section F12 of the new PRC
application.

On-Water Storage WAC 173-182-335 if a PRC must purchase and stage NEW dedicated
on-water storage equipment to meet this standard you must first submit your plan
to Ecology describing the equipment and staging location. Upon approval of
your plan you must list the new equipment on the WRRL. Notify Ecology when the
equipment is staged and listed on the WRRL. Ecology will schedule a
meeting with you to verify the equipment.

4 Hour Planning Standard
Update the WRRL to reflect the purchase of new equipment which meets the
capability required by this standard. Notify Ecology when the equipment is
staged and listed on the WRRL. Ecology will schedule a meeting with you to
verify the equipment.

Shoreline Cleanup WAC 173-182-522 Update shoreline clean-up information in
section F9 to describe any additional capabilities you purchased or staged to
align with the shoreline clean up requirements phasing in at 18 months. Notify
Ecology when the equipment is staged and listed on the WRRL. Ecology will
schedule a meeting with you to verify the equipment.

Question: Will I get a new PRC approval and expiration date based on my
new PRC application submittal or PRC application updates?

Answer: If you resubmit your entire PRC application, using the new
application form, you will receive a new approval and expiration date.

Alternatively, if you choose to update your existing application and ONLY submit
the sections which phase in at 18 months your current submittal and expiration
date stays the same. Ecology will accept either a complete submittal or
updates to your existing PRC application. Feel free to choose the option
that works best for your company.

When reviewing industry oil spill plans, we analyze whether
response equipment is in strategic locations that can be moved from a home base
to a potential spill site within certain planning timeframes. Standard travel
speeds of 35 miles per hour over land and 5 knots over water and 100 knots by
air are applied, unless
plan holders request alternative travel speeds and we grant them. Because you
own the equipment and keep records on performance, your customers will ask you
for help to meet this requirement (WAC 173-182-350).

In order for the request to be accepted by Ecology, new or
updated, alternative transit speed submissions should be conducted under one of
the following options:

OPTION 1: THE MEASURED MILE

Select a measured mile for your test location. This can be
a measured mile from designated/charted measured mile markers or between known
charted navigational aids. Run
the vessel on a measured mile a minimum of 4 runs (4 different directions). Runs
should be conducted with normal loads of fuel, water, personnel, boom and
recovery equipment on board. Record the following data and include in your
alternative request submission:

oVessel for which the alternative speed is requested

oSpeed Run Location

oDate of Run

oFor each of the 4 runs document

§Distance

§Engine RPM

§Elapsed Time

§Calculated Speed

§Document conditions of the day, wind/sea conditions

§Average the calculated speed of the four runs to determine the
alternative speed for the vessel

OPTION 2: TIME TEST

The
vessel must travel away from its home base in one direction for one hour.
The time test should be conducted with normal loads of fuel, water, personnel,
boom and recovery equipment on board. Record the following data and include in
your alternative request submission:

oRecord lat/long information every 10 minutes for both the
destination and return trip (total of approximately 2 hours)

oDescribe conditions of the day including weather and sea state
conditions.

oEngine RPM during the test

o
Calculated average speed

OPTION 3: VESSEL LOG

The vessel log should contain the following information:

o
Vessel arrival time and location, including latitude and longitude.

o
Vessel departure time and location, including latitude and longitude.

oSea
state conditions.

o
Description of load conditions. The log entry should be for a trip
conducted with normal loads of fuel, water, personnel, boom and recovery
equipment on board.

oEngine
RPM during the test

o
Calculated average speed

OPTION 4: SUBMIT DOCUMENTATION OF A USCG APPROVED
ALTERNATIVE SPEED

If a plan holder/PRC has documentation of a United States
Coast Guard approved alternative transit speed it may be submitted to Ecology
for review and approval.

If Ecology is invited to, and present during any of the
tests, the Ecology representative will record all the information for
documentation (detailed above). The requester will no longer need to submit
documentation.

If approval of alternate travel time is granted by ecology
you will receive a letter detailing the equipment and the approved travel
speeds.